CMS changes to hospital discharge planning

As part of the IMPACT (Improving Medicare Post-Acute Care Transformation) Act of 2014, CMS issued a final rule that empowers patients to make informed decisions about their care as they are discharged from acute-care to post-acute care.

New regulations associated with IMPACT go into effect on November 29, 2019 and the requirements are part of the conditions of participation for providers in the Medicare program. The intention of the regulations is to help patients achieve their care and treatment preferences.

The new requirements mandate providers to assist patients, their families, or the patient’s representative in selecting post-acute care services and suppliers. As part of the requirement, providers must use and share post-acute care data related to quality and resource use measures. A comprehensive list of facility choices must be made available to patients. CMS expects all providers to utilize and share publicly available information with their patients. The information shared need only be relevant to the specific discharge needs of the patient with the treatment goals at the forefront.

Changes to the discharge planning process

The facilities mentioned above must now discharge their patients with all of their current treatment information and goals. This must be done regardless of which type of facility a patient is discharged to and is inclusive of outpatient services and physicians.

HHAs must also share this information when they discharge a patient or transfer them to another HHA. In order to fulfill the conditions of program participation, iInformation must be shared at the time of transfer and not when specifically requested.

CMS’ push for interoperability

CMS is mandating this type of information sharing between facilities as an effort to improve interoperability. Interoperability is defined as the ability of health information systems to work together within and across organizational boundaries in order to advance the effective delivery of healthcare for individuals and communities. This allows patients and providers to have access to all the information necessary to properly treat and care for the patient, not just a specific test or result.

Hospitals must ensure and support patients’ rights to access their medical records in the format requested by the patient when possible. This includes hardcopy or electronic access to all of their information upon request.

The new rules are intended to improve provider and patient engagement in choices that affect the continuity of care across all healthcare settings, not just acute-care. The current presidential administration is committed to empowering patients and CMS is committed to supporting that goal. Access to critical health information is now available to patients like never before.

Transcript for “CMS changes to hospital discharge planning”:

Mike Passanante: Hi. This is Mike Passanante, and welcome back to the award-winning Hospital Finance Podcast.

CMS has some new rules in place regarding discharge planning. And they affect hospitals directly. Joining me today to discuss those changes is Mary Devine who is the Senior Director of Revenue Cycle Services here at BESLER.

Mary, welcome back to the podcast.

Mary Devine: Thank you for having me!

Mike Passanante: So Mary, as I just mentioned, there are some new requirements that go into effect at the end of November 2019, affecting discharge planning for hospitals. Tell us what’s going on there.

Mary Devine: Sure! So, this really goes all the way back to the IMPACT Act. And IMPACT is really short for Improving Medicare Post-Acute Care Transformation Act of 2014. So finally, CMS has issued a final rule. The final rule is really focused on empowering patients to make informed decisions about their care as they’re discharged from acute care into post-acute care settings. And what you’ll see is it’s not just in-patient post-acute setting, but as well as out-patient.

And you’re right, these regulations go into effect November 29th. And there are new requirements as part of their conditions of participation for all providers.

Mike Passanante: Okay, so let’s unpack that a little bit. What do the new requirements actually mandate?

Mary Devine: So, what the final rule does is it revises the requirements for hospitals—long-term care hospitals, in-patient rehab facilities, psychiatric facilities, children’s hospitals, cancer hospitals, as well as any other critical access and home health agencies.

And the biggest thing that I always want to say is some of these facilities currently don’t have any discharge requirements as it relates to providing additional information to other providers. Home health as an example, they don’t really have any discharge planning requirements. And heading into the new rule, they will.

And the new rule is really focused on the patient goals of care and treatment as well as making sure that their preferences are met. And it will allow them to have access to their medical record.

Mike Passanante: Mary, there are also some big changes to the discharge planning process. Can you explain them to us?

Mary Devine: Sure! I sort of alluded to that in my prior statement. But getting into a little more detail around it, the bigger change is the new discharge planning process for the facilities that I mentioned. And I think even the bigger change is again that home health agencies are now required to have discharge planning, where in the past, they didn’t have discharge planning.

So really, what it’s doing is it’s allowing patients with all their current treatment information and goals. And that is going to follow them to their next course of treatment.

So, again, this is not only for SNF’s and HHA’s but all post-acute providers. So you basically have to share all that information with the patient as well as with the next provider.

So, if a patient is being discharged from a home health agency and going into the care of their physician on an out-patient basis, then that home health information needs to go with the patient and be provided to the physician, so that the physician can again continue their care.

This is, again, all focused on the better outcomes of the patient care.

Mike Passanante: Mary, why do you think CMS issued these new requirements at this time?

Mary Devine: CMS is really focused on the interoperability. And just to define interoperability as it relates to healthcare, it is the ability of health information systems to work together within and across organizational boundaries in order to advance the effective delivery of healthcare for individuals and communities.

So really, to boil that down, what’s happening is it’s allowing patients and providers to have access to all the information to properly treat and care for that patient on an ongoing basis, and not just focus on that one specific test or result that the doctor might want to view or the patient might want to view.

So, as part of all this change, CMS is also requiring that hospitals ensure and support patient’s rights to access their medical record in the format requested by the patient when possible. So, it would either need to be hard copy or electronic depending on how the patient wants it. Some patients might not be able to do the electronic access into their EMR. So then you would have to provide them with a hard copy of all their medical record and not just one piece of it.

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